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Terms & Privacy Policy

Alpha version — last updated: March 2026

This document combines our Privacy Policy (Sections 1–11) and Terms of Service (Sections 12–16) into a single reference for the alpha period. Sections will be separated and updated before public launch.

Privacy Policy

1. What Protogen Is

Protogen is a wellness coaching platform that uses artificial intelligence to generate personalized wellness protocols. Protogen is not a medical service and does not provide medical advice, diagnosis, or treatment. All recommendations are for general wellness purposes only. Always consult a qualified healthcare professional before making changes to your health routine.

2. Data We Collect

3. How We Use Your Data

3a. Legal Basis for Processing (GDPR)

We process your personal data on the following legal bases under GDPR Article 6 and Article 9:

DataLegal Basis
Account information (email, password)Performance of contract — necessary to provide the service
Profile data (date of birth, sex, height, weight)Performance of contract — necessary to generate your wellness protocol
Wellness goalPerformance of contract
Usage data (timestamps, logs)Legitimate interests — maintaining service quality and security
Health documents (lab results, medical records)Explicit consent (GDPR Art. 9(2)(a)) — obtained at account creation by accepting these Terms & Privacy Policy
Genetic dataExplicit consent (GDPR Art. 9(2)(a)) — obtained via a dedicated consent flow before upload

You may withdraw consent for health document or genetic data processing at will. Withdrawal does not affect the lawfulness of processing before the withdrawal. To withdraw consent, delete the relevant files in your profile or contact privacy@protogen.life.

4. AI Processing (Third-Party Services)

Your profile data and uploaded documents are sent to OpenAI and/or Anthropic's API to generate wellness protocols.

5. Genetic Data

Genetic data receives special protection:

6. Data Storage and Security

Your uploaded health and genetic files are encrypted with a key we never see. Standard “encrypted at rest” means the service holds the key. We don't — only you do.

In the event of a personal data breach affecting your health or genetic data, we will notify you without undue delay and no later than 72 hours after becoming aware of the breach. Notification will be sent to the email address on your account and will describe: the nature of the breach, the data affected, the likely consequences, and the measures taken or proposed to address it. Where required by the FTC Health Breach Notification Rule, we will also notify the FTC within 60 calendar days of discovery.

7. Data Retention

Your data is retained as long as your account exists. You may request account deletion — this permanently removes your account and all associated data (protocols, documents, genetic files, usage history) from active systems. Residual copies in automated backups are purged within 30 days of deletion, after which no recoverable copy exists.

8. Your Rights

9. Alpha Program

Protogen is currently in alpha testing. By creating an account, you acknowledge that:

10. Changes to This Policy

We may update this document as the platform evolves. Significant changes will be communicated via email or in-app notification. Continued use after changes constitutes acceptance.

11. Automated Decision-Making

Protogen uses AI to generate wellness protocols based on your profile, uploaded documents, and genetic data. These recommendations are produced by automated processing without individual human review before delivery.

You have the right to:

To exercise these rights, contact privacy@protogen.life with the subject line “Protocol Review Request.”

Terms of Service

12. Governing Law

These terms are governed by applicable law. The governing jurisdiction will be confirmed and updated in this document prior to public launch, once the legal entity is registered. Users located in the EU retain the right to bring a claim before their local courts or supervisory authority regardless of the final jurisdiction.

13. Limitation of Liability

Protogen is provided “as is” during the alpha period. To the maximum extent permitted by applicable law:

Nothing in this section limits liability for death or personal injury caused by our negligence, fraud, or other liabilities that cannot be excluded by law.

14. Acceptable Use

You agree not to:

We reserve the right to suspend or terminate accounts that violate these terms without notice.

15. Intellectual Property

The Protogen platform, including its design, AI models, and software, is owned by the Protogen team. The registered legal entity name will be updated in this document prior to public launch. Wellness protocols generated for you are provided for your personal use. You retain ownership of all documents and data you upload.

16. Account Termination

We may suspend or permanently terminate your account if:

In the event of termination, we will notify you by email and your data deletion rights under Section 8 remain in effect.

17. Contact

For privacy questions, data requests, or protocol review requests, contact us at: privacy@protogen.life